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HMRC internal manual

VAT Civil Penalties

HM Revenue & Customs
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Misdeclaration penalty: Discretion, reasonable excuse, and mitigation: Change of legal entity

Please note: VAT Misdeclaration Penalty has been replaced by the Schedule 24 inaccuracy penalty for all accounting periods where the return period commences on or after 01/04/2008 and the due date is on or after 01/04/2009. Misdeclaration penalty will still apply where the due date is before 01/04/2009.

Please see the Compliance Handbook CH80000 Penalties for Inaccuracies for further details.

The following question should be addressed when considering reasonable excuse

  • Has the trader transferred from a partnership to a sole proprietor or vice versa?

Liability in these circumstances remains the same.